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Courts on AI / Fabricated or misquoted citations

In re: Kathleen A Rabon

U.S. Bankruptcy Court for the District of Connecticut · Federal bankruptcy courts · CT · · No. 25-21127 (JJT) · memorandum opinion

On 2026-04-03, U.S. Bankruptcy Court for the District of Connecticut denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations. Counsel submitted a motion with 7 false quotations. The response requirement preceded any sanction decision.

Disposition
The court denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations.
Recorded conduct
The motion used 7 false quotations that the court found nonexistent, misquoted, or unsupported for the propositions asserted. — outcome: pending; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

rejected any proposal that did not recognize him as the sole buyer of the Note. St.Germain blamed Daniel Malchman’s “eleventh hour tactic to get his wife and Russ named as co-assignees[,]” which St.Germain stated “kind of pissed me off[.]” 10 St.Germain, having initiated the Berkshire Bank transaction, unilaterally believed that he should own and control the Note. Attorney Liberty, however, testified that St.Germain’s loan approach was improvident and unacceptable, as it would render his clients unsecured creditors vulnerable to loss. Understandably, the risks of loss in St.Germain’s approach were too significant. As a consequence, no agreement was ever reached by St.Germain and Malchman and Russ. 11 Meanwhile, in Mark Rabon’s Chapter 7 case, the Movants moved for relief from stay under 11 U.S.C. § 362(d)(1), so as to continue the foreclosure process in the Superior Court. That motion went unopposed by the Debtor, Mark Rabon, and St.Germain and was subsequently granted. The Debtor then filed the instant case on October 24, 2025. By operation of law, the stay against the Debtor expired after 30 days because the Debtor’s prior Chapter 13 case had been dismissed within one year of the

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